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Dear user,

Welcome to 'LetsFamily.ch'! 'LetsFamily.ch' is a free online platform for expectant and young parents, where informative guide content published by renowned experts and on the other hand various free promotions , especially free gifts, vouchers and competitions from us and our sponsors You can take part in all promotions free of charge. All you have to do is register/log in and, if necessary, agree to the participation criteria set by the respective sponsor.

LetsFamily.ch processes personal data to enable the best possible user experience, in particular to display campaigns that are relevant/interesting for the user or to determine whether a user is eligible to participate or meets the criteria (rules) set by the sponsor, or to ensure the smooth processing of the individual services/campaigns. Your trust is our top priority! For this reason, LetsFamily.ch takes the protection of your personal data very seriously and adheres to the applicable statutory data protection regulations to the best of its knowledge and belief, in particular the Swiss Federal Data Protection Act (DSG), the EU General Data Protection Regulation (GDPR) and the Act against Unfair Competition (UWG). The following data protection declaration gives you a detailed overview of how LetsFamily.ch ensures this protection and which types of data are collected, stored and used (processed) for what purpose. Please read this data protection declaration and the conditions of participation carefully. If you do not want 'LetsFamily.ch' to use your data to show you relevant/interesting promotions or to inform you about them, then you should not register with 'LetsFamily.ch'. Because that is exactly what 'LetsFamily.ch' does for you: 'LetsFamily.ch' and its sponsors inform you about promotions that are relevant/interesting to you, which are of course advertising in some way. If you just want to test 'LetsFamily.ch' for a while, fine! You can manage your data protection settings at any time in your profile settings or even delete your account completely.

The best thing to do is to simply try out 'LetsFamily.ch' and then decide whether 'LetsFamily.ch' offers you the desired added value.

With this in mind, we wish you lots of fun and luck at 'LetsFamily.ch'!

Best regards,

Your LetsFamily team

PS To simplify the reading of this privacy policy, we have decided to use the English – gender-neutral! – term 'User'. Thank you for your understanding!

1. What is this privacy policy about?

LetsFamily.ch (hereinafter also 'we', 'us') acquires and processes personal data that concerns you or other persons (so-called 'third parties'). We use the term 'data' here synonymously with 'personal data' or 'personal information'. This privacy policy applies to all users of our website, services and products (hereinafter also 'users', 'customers', 'contract partners', 'sponsors').

'Personal data' refers to data that relates to a specific or identifiable person, i.e. conclusions about their identity can be drawn from the data itself or with corresponding additional data. 'Particularly sensitive personal data' is a category of personal data that is particularly protected under applicable data protection law. Particularly sensitive personal data includes, for example, data that reveals racial and ethnic origin, health data, information about religious or ideological beliefs, biometric data for identification purposes and information about trade union membership. In section 3 you will find information about the data that we process within the framework of this data protection declaration. 'Processing' means any handling of personal data, e.g. obtaining, storing, using, adapting, disclosing and deleting.

In this privacy policy we describe what we do with your data when you use LetsFamily.ch, other websites/subdomains of ours (e.g. club.letsfamily.ch, LetsFamily.club, merchant.letsfamily.ch) or our apps (hereinafter collectively referred to as the 'website'), purchase our services or products, otherwise contact us under a contract, communicate with us or otherwise deal with us. If necessary, we will inform you by timely written notice of additional processing activities not mentioned in this privacy policy. In addition, we may inform you separately about the processing of your data, e.g. in declarations of consent, contractual terms, additional privacy statements, forms and notices.

If you send us or disclose data about other people, such as family members, work colleagues, etc., we assume that you are authorized to do so and that this data is correct. By transmitting data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy statement. This privacy statement is designed to meet the requirements of the EU General Data Protection Regulation ('GDPR'), the Swiss Data Protection Act ('DSG') and the revised Swiss Data Protection Act ('revDSG'). However, whether and to what extent these laws are applicable depends on the individual case.

2. Who is responsible for processing your data?

For the data processing described in this privacy policy, the Eco Generation GmbH, Chollerstrasse 3, 6300 Zug (hereinafter also ' LetsFamily.ch '), is responsible, unless otherwise communicated in individual cases, e.g. in further data protection declarations, on forms or in contracts. Unless otherwise communicated, this data protection declaration also applies to cases in which LetsFamily.ch, but a group company of the Present-Service Group, is not the responsible party. This is particularly the case where your data is processed by such a group company in connection with its own legal obligations or contracts, or where you share data with such a group company. In these cases, this group company is the responsible body and only if they share your data with other group companies for their own purposes (see Section 7), these other group companies also become responsible bodies.

The 'Present-Service Group' refers to Present-Service Henckel von Donnersmarck & co., Chollerstrasse 3, 6300 Zug and its subsidiaries and group companies:

  • Eco Generation GmbH, Chollerstrasse 3, CH-6300 Zug
  • Felicitas Promotions AG, Chollerstrasse 3, CH-6300 Zug
  • Validad AG, Chollerstrasse 3, CH-6300 Zug
  • Validad GmbH, Karmeliterplatz 1/3, A-1020 Vienna

For each data processing operation, there is one or more bodies that are responsible for ensuring that the processing complies with the requirements of data protection law. This body is called the controller. It is responsible, for example, for answering requests for information (Section 11) or ensuring that personal data is secured and not used in an unauthorized manner.

Other parties may also be jointly responsible for the data processing described in this data protection declaration if they have a say in the purpose or design. All group companies are eligible. If you would like information about the individual persons responsible for a specific data processing, you are welcome to request information from us within the scope of your right to information (Section 11). LetsFamily.ch remains your primary contact, even if there are other jointly responsible parties.

In section 3, section 7 and section 12 you will find further information about third parties with whom we work and who are responsible for their processing. If you have any questions or wish to exercise your rights with regard to these third parties, please contact them directly.

A list of third parties to whom we may pass on your data or who may be jointly responsible for processing your data can be found here [link, whereby a distinction should be made on this list between the two categories (processors and [jointly] responsible parties)].

You can contact us for your data protection concerns and to exercise your rights in accordance with Section 11 as follows:

Eco Generation GmbH
Chollerstrasse 3
CH-6300 Zug
datenschutz@mail.letsfamily.ch

3. What data do we process?

We process different categories of data about you. The main categories are as follows:

  • Technical data: When you use our website or other electronic services (e.g. free WiFi), we collect the IP address of your device and other technical data to ensure the functionality and security of these services. This data also includes logs in which the use of our systems is recorded. We generally store technical data for 6 months. To ensure the functionality of these services, we can also assign you or your device an individual code (e.g. in the form of a cookie, see section 12). The technical data itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, it can be linked to other data categories (and thus possibly to you personally).

    The technical data includes, among other things, the IP address and information about the operating system of your device, the date, region and time of use, as well as the type of browser you use to access our electronic offerings. This can help us to provide the correct formatting of the website or, for example, to show you a website tailored to your region. Based on the IP address, we know which provider you use to access our offerings (and therefore also the region), but we cannot usually deduce who you are from this. This changes if, for example, you create a user account, because then personal data can be linked to technical data (we can see, for example, which browser you use to open an account on our website). Examples of technical data also include logs that are generated in our systems (e.g. the log of user logins on our website).

  • Registration data: Certain offers, e.g. competitions and services (e.g. login areas of our website, newsletter distribution, free WiFi access, etc.) can only be used with a user account or registration, which can be done directly with us or through our external login service providers. You must provide us with certain data and we collect data about the use of the offer or service. If you redeem/activate a voucher with us, we may request certain data from you when redeeming it. If we issue you a voucher for one of our contractual partners, we may send the respective contractual partner certain of your registration data or receive such data (see section 7). Registration data may be generated when accessing certain facilities. We generally retain registration data for 12 months after the end of use of the service or the closure of the user account.

    Registration data includes the information you provide when you create an account on our website (e.g. user name, password, name, email). Registration data also includes data that we may require from you before you can use certain free services, such as redeeming vouchers, in this case: name, address, contact details, time of redemption. You must also register if you want to subscribe to our newsletter. As part of access controls, we may have to register you with your data (see the category 'other data').

  • Communication data: If you contact us via the contact form, by email, telephone, chat, letter or other means of communication, we record the data exchanged between you and us, including your contact details and the peripheral data of the communication. If we record or listen in on telephone conversations or video conferences, e.g. for training and quality assurance purposes, we will draw your attention to this. Such recordings may only be made and used in accordance with our internal guidelines. You will be informed whether and when such recordings take place, e.g. by a display during the video conference in question. If you do not want a recording, please let us know or end your participation. If you simply do not want your image to be recorded, please switch off your camera. If we want or need to establish your identity, e.g. if you request information, apply for media access, etc., we collect data to identify you (e.g. a copy of an ID card). We generally keep this data for 12 months from the last exchange with you. This period may be longer if this is necessary for evidentiary reasons or to comply with legal or contractual requirements or for technical reasons. Emails in personal mailboxes and written correspondence are generally kept for at least 10 years.

    Communication data is your name and contact details, the manner, location and time of communication and usually also its content (i.e. the content of emails, letters, chats, etc.). This data may also contain information about third parties.

  • master data: We refer to master data as the basic data that we require, in addition to the contract data (see below), for the processing of our contractual and other business relationships or for marketing and advertising purposes. We process your master data if you are a customer or other business contact or work for such a contact (e.g. as a contact person for a business partner), or because we want to address you for our own purposes or the purposes of a contractual partner (e.g. in the context of marketing and advertising, with invitations to events, with vouchers, with newsletters, etc.). We receive master data from you (e.g. when making a purchase or as part of a registration) or from third parties such as our contractual partners, associations and address dealers and from publicly accessible sources such as public registers or the Internet (websites, social media, etc.). We can also process health data and information about third parties as part of master data. Data is generally stored for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.

    Master data includes, for example, data such as name, address, email address, telephone number and other contact details, gender, date of birth, nationality, information on associated persons, websites, social media profiles, photos and videos, copies of ID cards; furthermore, information about your relationship with us (customer, supplier, visitor, service recipient, etc.), information about your status with us, allocations, classifications and distribution lists, information about our interactions with you (possibly a history of these with corresponding entries), reports (e.g. from the media) or official documents (e.g. commercial register extracts, permits, etc.) that concern you. As payment information, we collect, for example, your bank details, account number and credit card details. Consent or blocking notes also belong to master data, as does information about third parties, e.g. contact persons, recipients of services, advertising recipients or representatives.

    For contact persons and representatives of our customers, suppliers and partners, we process master data such as name and address, information on role, function in the company, qualifications and, if applicable, information on superiors, employees and subordinates and information on interactions with these persons.

    Master data is not collected comprehensively for all contacts. Which data we collect in detail depends in particular on the purpose of processing.

  • Contract data: This is data that arises in connection with the conclusion or processing of a contract, e.g. information about contracts and the services to be provided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information about reactions (e.g. complaints or information on satisfaction, etc.). This also includes health data and information about third parties. We usually collect this data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third-party sources (e.g. providers of credit data) and from publicly accessible sources. We generally keep this data for 10 years from the last contractual activity, but at least from the end of the contract. This period can be longer if this is necessary for reasons of evidence or to comply with legal or contractual requirements, or for technical reasons.

    Contract data includes information about the conclusion of the contract, about your contracts, e.g. the type and date of the conclusion of the contract, information from the application process (such as an application for our products or services) and information about the contract in question (e.g. its duration) and the processing and administration of the contracts (e.g. information related to invoicing, customer service, support with technical matters and the enforcement of contractual claims). Contract data also includes information about defects, complaints and adjustments to a contract, as well as information on customer satisfaction, which we can collect, for example, through surveys. Contract data also includes financial data such as information on creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood that claims will be settled), reminders and debt collection. We receive some of this data from you (e.g. when you make payments), but also from credit agencies and debt collection companies and from publicly accessible sources (e.g. a commercial register).

  • Behavioral and preference data: Depending on the relationship we have with you, we try to get to know you and tailor our products, services and offers to you better. To do this, we collect and use data about your behavior and preferences. We do this by evaluating information about your behavior in our area, and we can also supplement this information with information from third parties - including from publicly accessible sources. Based on this, we can, for example, calculate the likelihood that you will use certain services or behave in a certain way. Some of the data processed for this purpose is already known to us (e.g. if you use our services), or we obtain this data by recording your behavior (e.g. how you navigate on our website). We describe how tracking works on our website in section 12.

    Behavioral data is information about certain actions, e.g. your response to electronic communications (e.g. whether and when you opened an email) or your location, as well as your interaction with our social media profiles and your participation in prize draws, competitions and similar events. We may collect your location data wirelessly, for example, through unique codes that your mobile phone sends out or when you use our website.

    Preference data tells us what your needs are, what products or services might be of interest to you, or when and how you are likely to respond to messages from us. We obtain this information from the analysis of existing data, such as behavioral data, so that we can get to know you better, tailor our advice and offers more precisely to you, and generally improve our offers. To improve the quality of our analyses, we can link this data with other data that we also obtain from third parties such as address dealers, authorities and publicly accessible sources such as the Internet, e.g. with information on your household size, income class and purchasing power, shopping behavior and contact details of relatives and anonymous information from statistical offices.

    Behavioral and preference data can be evaluated on a personal basis (e.g. to show you personalized advertising), but also non-personally (e.g. for market research or product development). Behavioral and preference data can also be combined with other data

  • Other data: We also collect data from you in other situations. In connection with official or legal proceedings, for example, data arises (such as files, evidence, etc.) that may also relate to you. We may receive or create photos, videos and sound recordings in which you may be recognizable (e.g. at events, through security cameras, etc.). We may also collect data on who enters certain buildings and when or has corresponding access rights (including during access controls, based on registration data or visitor lists, etc.), who takes part in events or campaigns (e.g. competitions) and when, or who uses our infrastructure and systems and when. The retention period for this data depends on the purpose and is limited to what is necessary.

You provide us with much of the data mentioned in this section 3 yourself (e.g. via forms, when communicating with us, in connection with contracts, when using the website, etc.). You are not obliged to do so. If you wish to conclude contracts with us or claim services, you must also provide us with data as part of your contractual obligation in accordance with the relevant contract, in particular master, contract and registration data. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving your consent.

We only make certain services available to you if you send us registration data because we or our contractual partners want to know who is using our services or has accepted an invitation to an event, because it is technically necessary or because we want to communicate with you. If you or a person you represent (e.g. your employer) wants to conclude or fulfill a contract with us, we must collect the relevant master, contract and communication data from you, and we process technical data if you want to use our website or other electronic offers for this purpose. If you do not provide us with the data required to conclude and process the contract, you must expect that we will refuse to conclude the contract, that you will breach the contract or that we will not fulfill the contract. Likewise, we can only send you a response to an inquiry from you if we process the relevant communication data and - if you communicate with us online - possibly also technical data. It is also not possible to use our website without us receiving technical data.

Unless this is prohibited, we also obtain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the Internet including social media) or receive data from other companies within our group, from authorities and from other third parties (such as credit agencies, address dealers, associations, contractual partners, Internet analysis services, etc.).

The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities (so that we can, for example, conclude and process business with your employer with your help), information about you in correspondence and meetings with third parties, credit reports (if we conduct business with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) give us so that we can conclude or process contracts with you or with your involvement (e.g. references, your address for deliveries, powers of attorney, information on compliance with legal requirements such as those relating to the fight against fraud, money laundering and terrorism and export restrictions, information from banks, insurance companies and sales and other contractual partners of ours regarding the use or provision of services by you (e.g. payments, purchases, etc.), information from the media and the Internet about you (if this is appropriate in the specific case, e.g. in the context of an application, Marketing/sales, press reviews, etc.), your address and, if applicable, interests and other socio-demographic data (in particular for marketing and research) and data in connection with the use of third-party websites and online offers, where this use can be assigned to you.

4. For what purposes do we process your data?

We process your data for the purposes that we explain below. You can find further information for the online area in sections 12 and 13. These purposes or the goals underlying them represent legitimate interests of us and, where applicable, of third parties. You can find further information on the legal basis for our processing in section 5. We process your data for purposes related to communication with you, in particular to answer inquiries and assert your rights (section 11) and to contact you if you have any questions. For this purpose, we use communication data and master data in particular and, in connection with offers and services used by you, also registration data. We keep this data in order to document our communication with you, for training purposes, for quality assurance and for inquiries.

This concerns all purposes in connection with which you and we communicate, whether in customer service or advice, for authentication in the event of use of the website or for training and quality assurance (e.g. in the area of ​​customer service). We further process communication data so that we can communicate with you by email and telephone, as well as messenger services, chat, social media, letter and fax. Communication with you usually takes place in connection with other processing purposes, e.g. so that we can provide services or respond to a request for information. Our data processing also serves to prove communication and its content. We process data for the establishment, administration and processing of contractual relationships.

We conclude contracts of all kinds with our business and private customers, with suppliers, subcontractors or other contractual partners such as partners in projects or with parties in legal disputes. In particular, we process master data, contract data and communication data and, depending on the circumstances, also registration data of the customer or the people to whom the customer provides a service. This includes, for example, the recipients of our products or services who receive vouchers and invitations from our customers and who can become our customers when they redeem them. In this case, we process data for the execution of the contract with these recipients, but also with the contractual partners who invited them.

As part of the business initiation process, personal data - in particular master data, contract data and communication data - is collected from potential customers or other contractual partners (e.g. in an order form or contract) or results from communication. We also process data in connection with the conclusion of the contract to check creditworthiness and to open the customer relationship. In some cases, this information is checked to ensure compliance with legal requirements.

As part of the processing of contractual relationships, we process data to manage the customer relationship, to provide and demand contractual services (which also includes the involvement of third parties such as logistics companies, security services, advertising service providers, banks, insurance companies or credit agencies, which can then provide us with data of their own), for advice and for customer service. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the processing, as is bookkeeping, termination of contracts and public communication.

We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalized advertising about our products and services and those of third parties (e.g. from advertising contractual partners). This can take the form of newsletters and other regular contacts (electronically, by post, by telephone), via other channels for which we have contact information from you, but also as part of individual marketing campaigns (e.g. events, competitions, etc.) and also include free services (e.g. invitations, vouchers, etc.). You can reject such contacts at any time (see the end of this section 4) or refuse or revoke your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the Internet more specifically to you (see section 12). Finally, we also want to enable our contractual partners to contact our customers and other contractual partners for advertising purposes (see section 7).

For example, with your consent, we will send you information, advertising and product offers from us and from third parties within and outside the group (e.g. advertising partners), in printed form, electronically or by telephone. To do this, we primarily process communication and registration data. Like most companies, we personalize messages so that we can send you individual information and make offers that match your needs and interests. To do this, we link data that we process about you and determine preference data and use this data as the basis for personalization (see section 3). We also process data in connection with competitions, prize draws and similar events.

Relationship management also includes addressing existing customers and their contacts - possibly personalized based on behavior and preference data. As part of relationship management, we can also operate a customer relationship management system ('CRM') in which we store the data required to maintain relationships with customers, suppliers and other business partners, e.g. about contact persons, relationship history (e.g. about products and services purchased or delivered, interactions, etc.), interests, wishes, marketing measures (newsletters, invitations to events, etc.) and other information.

All of these processes are important to us not only to promote our offers as effectively as possible, but also to make our relationships with customers and other third parties more personal and positive, to focus on the most important relationships and to use our resources as efficiently as possible.

We will continue to process your data for market research, to improve our services and operations, and for product development.

We strive to continually improve our products and services (including our website) and to be able to respond quickly to changing needs. We therefore analyze, for example, how you navigate through our website or which products are used by which groups of people in which way and how new products and services can be designed (for further details see section 12). This gives us information about the market acceptance of existing products and services and the market potential of new ones. To do this, we process master, behavioral and preference data in particular, but also communication data and information from customer surveys, polls and studies and other information, e.g. from the media, social media, the Internet and other public sources. Where possible, we use pseudonymized or anonymized information for these purposes. We can also use media monitoring services or carry out media monitoring ourselves and process personal data in order to carry out media work or to understand and respond to current developments and trends. We use anonymized location data, for example, to give our contractual partners recommendations for avoiding peak times. With your consent, we use non-anonymized location data to inform you of interesting offers and products nearby based on your location, to draw conclusions about your interests from the location data (length of stay) and to inform you which products and services other contractual partners with similar interests have used. We can also process your data for security purposes and for access control.

We continually check and improve the appropriate security of our IT and other infrastructure (e.g. buildings). Like all companies, we cannot completely rule out data security breaches, but we do our best to reduce the risks. We therefore process data for monitoring, checking, analyzing and testing our networks and IT infrastructures, for system and error testing, for documentation purposes and as part of backup copies. Access controls include, on the one hand, controlling access to electronic systems (e.g. logging into user accounts), but on the other hand also physical access control (e.g. building access). We process personal data to comply with laws, instructions and recommendations from authorities and internal regulations ('compliance').

This includes, for example, the implementation of health and safety concepts or the legally regulated fight against money laundering and terrorist financing. In certain cases, we may be obliged to carry out certain investigations into customers ('Know Your Customer') or to report to authorities. The fulfilment of disclosure, information or reporting obligations, for example in connection with supervisory and tax law obligations, also requires or entails data processing, e.g. the fulfilment of archiving obligations and the prevention, detection and clarification of criminal offenses and other violations. This also includes the receipt and processing of complaints and other reports, the monitoring of communications, internal investigations or the disclosure of documents to an authority if we have sufficient reason to do so or are legally obliged to do so. Your personal data may also be processed in the event of external investigations, e.g. by a law enforcement or supervisory authority or a commissioned private body. For all of these purposes, we process in particular your master data, your contract data and communication data, but under certain circumstances also behavioral data and data from the category of other data. The legal obligations may be Swiss law, but also foreign regulations to which we are subject, as well as self-regulations, industry standards, our own corporate governance and official instructions and requests.

We also process data for the purposes of our risk management and as part of prudent corporate governance, including business organization and corporate development.

For these purposes, we process master data, contract data, registration data and technical data in particular, but also behavioral and communication data. For example, as part of our financial management, we must monitor our debtors and creditors, and we must avoid becoming victims of crimes and abuses, which may require the analysis of data for corresponding patterns. For these purposes and to protect you and us from criminal or abusive activities, we may also carry out profiling and create and edit profiles (see also section 6). As part of planning our resources and organizing our business, we must evaluate and process data on the use of our services and other offers or exchange information about them with others (e.g. outsourcing partners), which may also include your data. The same applies to services provided to us by third parties. As part of the company's development, we may sell businesses, business units or companies to or acquire them from others or enter into partnerships, which may also lead to the exchange and processing of data (including from you, e.g. as a customer or supplier or as a supplier representative). We may process your data for other purposes, e.g. as part of our internal processes and administration or for training and quality assurance purposes.

These additional purposes include, for example, training and educational purposes, administrative purposes (such as the management of master data, accounting and data archiving and the testing, management and ongoing improvement of IT infrastructure), the protection of our rights (e.g. to enforce claims in court, before or out of court and before authorities at home and abroad or to defend ourselves against claims, for example by securing evidence, legal clarifications and participation in court or administrative proceedings) and the evaluation and improvement of internal processes. We can use recordings of (video) conferences for training and quality assurance purposes. The protection of other legitimate interests is also one of the other purposes, which cannot be listed exhaustively.

5. On what basis do we process your data?

If we ask for your consent for certain processing operations (e.g. for the processing of particularly sensitive personal data, for marketing mailings, for the creation of personalized movement profiles and for advertising control and behavior analysis on the website), we will inform you separately about the corresponding purposes of the processing. You can revoke your consent at any time with effect for the future by sending us a written notification (by post) or, unless otherwise stated or agreed, by email; our contact details can be found in section 2. For the revocation of your consent for online tracking, see section 12. If you have a user account, you can also revoke your consent or contact us via the relevant website or other service. As soon as we have received notification of the revocation of your consent, we will no longer process your data for the purposes to which you originally consented, unless we have another legal basis for doing so. The revocation of your consent does not affect the legality of the processing carried out on the basis of the consent up to the time of revocation.

Where we do not ask for your consent to process data, we base the processing of your personal data on the fact that the processing is necessary for the initiation or execution of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, in particular in order to pursue the purposes and associated objectives described above under section 4 and to be able to carry out appropriate measures. Our legitimate interests also include compliance with statutory provisions, insofar as these are not already recognized as a legal basis by the applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and Switzerland). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and developing our company, including its operations, safely and efficiently.

If we receive sensitive data (e.g. health data, information about political, religious or ideological views or biometric data for identification), we may also process your data based on other legal bases, e.g. in the event of disputes due to the need to process the data for a possible legal process or to enforce or defend against legal claims. In individual cases, other legal grounds may apply, which we will communicate to you separately if necessary.

6. What applies to profiling and automated individual decisions?

We can automatically evaluate certain of your personal characteristics for the purposes stated in section 4 using your data (section 3) ('profiling') if we want to determine preference data, but also to determine misuse and security risks, carry out statistical evaluations or for operational planning purposes. We can also create profiles for the same purposes, i.e. we can combine behavior and preference data, but also master and contract data and technical data assigned to you in order to better understand you as a person with your different interests and other characteristics. We can also create anonymous and - with your consent - personalized movement profiles of you.

If you are one of our customers, we can, for example, use 'profiling' to determine which other products you are likely to be interested in based on your purchases. We can also use this to check your creditworthiness before we offer you a purchase on account. An automated evaluation of data can also, for your protection, check the probability that a certain transaction was fraudulent. This allows us to stop the transaction for clarification. A distinction must be made between these and 'profiles'. This means the linking of different data in order to gain clues about essential aspects of your personality from the totality of this data (e.g. what you like or how you behave in certain situations). Profiles can also be used for marketing, for example, but also for security purposes.

We use anonymous movement profiles in a non-personal manner, for example to give our contractual partners recommendations for avoiding peak times. For personalized movement profiles, we use personal data, for example to point out interesting offers and products in your area, to draw conclusions about your interests from the location data (length of stay) and to inform you which products and services other contractual partners with similar interests have used or, for example, where health-related protection concepts require contact tracing.

In both cases, we ensure that the results are proportionate and reliable and take measures against any misuse of these profiles or profiling. If these could have legal consequences or significant disadvantages for you, we generally carry out a manual review.

In certain situations, for reasons of efficiency and uniformity of decision-making processes, it may be necessary for us to automate discretionary decisions concerning you that have legal effects or potentially significant disadvantages ('automated individual decisions'). In this case, we will inform you accordingly and provide the measures required by applicable law.

An example of an automated individual decision is the automatic acceptance of an order by an online shop. This does not mean pure if-then decisions (e.g. if the computer lets you access your user account after checking your password), but rather discretionary decisions (e.g. the decision to conclude a contract). We will inform you in each individual case if an automated decision leads to negative legal consequences or a comparable significant impairment for you. If you do not agree with the result of such a decision, you will be able to communicate with a person who will review the decision.

7. Who do we disclose your data to?

In connection with our contracts, the website, our services and products, our legal obligations or otherwise to protect our legitimate interests and the other purposes listed in section 4, we also transmit your personal data to third parties, in particular to the following categories of recipients:

  • Group companies: The group companies can use the data in accordance with this data protection declaration for the same purposes as we do (see section 4). We can also disclose health data to our group companies.

    The group companies receive access in particular to your master data, contract and registration data as well as behavior and preference data in order to make you offers from their own range of products and services or to advertise them. If you wish to object to the transfer and use for marketing purposes, you can do so through us (Section 2), even if this concerns another group company because data has already been transmitted. We also transmit your data to other group companies for certain products and services, e.g. if certain products and services come from group companies other than us and we only coordinate the processing.

  • Service providers: We work with service providers in Germany and abroad who process data about you on our behalf or under joint responsibility with us, or who receive data about you from us under their own responsibility (e.g. IT providers, shipping companies, advertising service providers, login service providers, cleaning companies, security companies, banks, insurance companies, debt collection companies, credit agencies or address checkers). This may also include health data. For the service providers used for the website, see section 12.

    We obtain services from third parties in numerous areas so that we can provide our products and services efficiently and concentrate on our core competencies. These services include, for example, IT services, the sending of information, marketing, sales, communication or printing services, building management, security and cleaning, the organization and implementation of events and receptions, debt collection, credit agencies, address checkers (e.g. to update address lists when moving), anti-fraud measures and services from consulting firms, lawyers, banks, insurers and telecommunications companies. We provide these service providers with the data required for their services, which may also concern you. These service providers can also use such data for their own purposes, e.g. information about outstanding debts and your payment history in the case of credit agencies or anonymized information to improve services. In addition, we conclude contracts with these service providers that contain provisions for the protection of data, unless such provisions arise from the law. Our service providers may process data on how their services are used and other data that arise in the context of the use of their services as independent controllers for their own legitimate interests (e.g. for statistical evaluations or billing). Service providers provide information about their independent data processing in their own data protection declarations.

  • Contractual partners including customers: This primarily refers to our customers (e.g. service recipients) and other contractual partners, because this data transfer results from these contracts. For example, you will receive registration data for vouchers issued and redeemed, invitations, etc. If you work for such a contractual partner yourself, we can also transmit data about you to them in this context. This can also include health data. The recipients also include contractual partners with whom we cooperate or who advertise for us and to whom we therefore transmit data about you for analysis and marketing purposes (these can in turn be service recipients, but also, for example, sponsors and providers of online advertising). We require these partners to only send you advertising or display it based on your data if you have consented to this (for the online area, see section 12). Our central cooperation partners are here our online advertising partners are listed in section 12.

    If you work for a company with which we have a contract, the execution of this contract may result in us informing the company, for example, how you have used our service. Cooperation and advertising contract partners receive selected master, contract, behavior and preference data from us so that they can, on the one hand, carry out non-personal evaluations in their area (e.g. on the number of our customers who have viewed their advertising) and, on the other hand, they can also use data for advertising purposes (including targeting you). For example, advertising contract partners should have the opportunity to communicate with other suitable customers of ours and send them advertising.

  • authorities: We may pass on personal data to offices, courts and other authorities at home and abroad if we are legally obliged or authorized to do so or if this appears necessary to protect our interests. This may also include health data. The authorities process data about you that they receive from us under their own responsibility.

    Examples of use include criminal investigations, police measures (e.g. health protection concepts, combating violence, etc.), regulatory requirements and investigations, court proceedings, reporting obligations and pre- and extra-judicial proceedings as well as statutory information and cooperation obligations. Data may also be disclosed if we want to obtain information from public bodies, e.g. to justify an interest in information or because we need to say who we need information about (e.g. from a register).

  • Other people: This refers to other cases where the involvement of third parties arises from the purposes set out in section 4, e.g. service recipients, media and associations in which we participate or if they are part of one of our publications.

    Other recipients include, for example, delivery addresses or third-party payment recipients specified by you, other third parties, including those within the framework of representative relationships (e.g. if we send your data to your lawyer or bank), or people involved in official or court proceedings. If we work with the media and send them material (e.g. photos), you may also be affected. The same applies when content (e.g. photos, interviews, quotes, etc.) is published on the website or in other publications by us. As part of our corporate development, we may sell or acquire businesses, parts of operations, assets or companies, or enter into partnerships, which may also result in the disclosure of data (including yours, e.g. as a customer or supplier or as a supplier representative) to the people involved in these transactions. As part of our communication with our competitors, industry organizations, associations and other bodies, data that also concerns you may also be exchanged.

All of these categories of recipients can in turn involve third parties, so that your data can also be accessed by them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.). We reserve the right to disclose data even if it concerns confidential data (unless we have expressly agreed with you that we will not pass this data on to certain third parties unless we are legally obliged to do so). Notwithstanding this, your data will continue to be subject to appropriate data protection even after disclosure in Switzerland and the rest of Europe. The provisions of section 8 apply to disclosure to other countries. If you do not want certain data to be passed on, please let us know so that we can check whether and to what extent we can accommodate you (section 2). In many cases, the disclosure of confidential data is also necessary in order to process contracts or provide other services. Non-disclosure agreements do not usually exclude such disclosure of data, nor does disclosure to service providers. However, depending on the sensitivity of the data and other circumstances, we ensure that these third parties handle the data appropriately. We cannot comply with your objection to data transfer if the data disclosure in question is necessary for our activities.

We also allow certain third parties to collect personal data from you on our website and on our own occasions (e.g. media photographers, providers of tools that we have integrated into our website, etc.). To the extent that we are not significantly involved in this data collection, these third parties are solely responsible for it. If you have any concerns or wish to assert your data protection rights, please contact these third parties directly. See section 12 for the website.

8. Will your personal data also be transferred abroad?

As explained in section 7, we also disclose data to other entities. These are not only located in Switzerland. Your data may therefore be processed in Europe as well as in the United States of America; in exceptional cases, however, in any country in the world.

If a recipient is located in a country without adequate legal data protection, we will contractually oblige the recipient to comply with the applicable data protection (for this purpose we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognized set of rules to ensure data protection and we cannot rely on an exception. An exception may apply in particular in legal proceedings abroad, but also in cases of overriding public interests or if the execution of a contract requires such disclosure, if you have consented or if the data is data that you have made generally available and whose processing you have not objected to.

Many countries outside Switzerland or the EU and EEA do not currently have laws that guarantee an adequate level of data protection from the perspective of the DSG or the GDPR. This weaker or lacking legal protection can be partially compensated for with the contractual provisions mentioned. However, contractual provisions cannot eliminate all risks (namely from government access abroad). You should be aware of these residual risks, even if the risk may be low in individual cases and we take further measures (e.g. pseudonymization or anonymization) to minimize it.

Please also note that data exchanged over the Internet is often routed via third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

LetsFamily.ch uses external fonts, Google Fonts. Google Fonts is a service provided by Google Inc. ("Google"). These web fonts are integrated by calling a server, usually a Google server in the USA. The IP address of the browser on the device of the visitor to this website is also processed by Google. You can find more information in Google's privacy policy at: www.google.com/policies/privacy/

9. How long do we process your data?

We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes require it, or if storage is technically necessary. Further information on the respective storage and processing periods can be found for the individual data categories in Section 3 or for the cookie categories in Section 12. If there are no legal or contractual obligations to the contrary, we will delete or anonymize your data after the storage or processing period has expired as part of our usual procedures. Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in the event of legal claims, discrepancies, IT and infrastructure security purposes and proof of good corporate governance and compliance. Storage may be necessary for technical reasons if certain data cannot be separated from other data and we therefore have to store it with it (e.g. in the case of backups or document management systems).

10. How do we protect your data?

We take appropriate security measures to protect the confidentiality, integrity and availability of your personal data, to protect it against unauthorized or unlawful processing and to counteract the risks of loss, accidental alteration, unwanted disclosure or unauthorized access.

Security measures of a technical and organizational nature may include measures such as encryption and pseudonymization of data, logging, access restrictions, storage of backup copies, instructions to our employees, confidentiality agreements and controls. We protect your data transmitted via our website during transport using suitable encryption mechanisms. However, we can only secure areas that we control. We also require our contract processors to take appropriate security measures. However, security risks cannot generally be completely ruled out; residual risks are unavoidable.

11. What rights do you have?

Applicable data protection law grants you the right to object to the processing of your data, in particular for direct marketing purposes, profiling for direct marketing purposes and other legitimate interests in processing, under certain circumstances.

To make it easier for you to control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and which data we process about you;

  • the right to have us correct data if it is inaccurate;

  • the right to request the erasure of data;

  • the right to request that we provide you with certain personal data in a common electronic format or to transmit them to another controller;

  • the right to withdraw consent where our processing is based on your consent;

  • the right to obtain, upon request, further information necessary to exercise these rights;

  • the right to express your point of view in the case of automated individual decisions (Section 6) and to request that the decision be reviewed by a natural person.

If you wish to exercise the above rights against us (or against one of our group companies), please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; our contact details can be found in section 2. In order to rule out misuse, we must identify you (e.g. with a copy of your ID card, if this is not possible otherwise).

You also have these rights vis-à-vis other bodies that work with us independently - please contact them directly if you wish to exercise rights in connection with their processing. Information about our important cooperation partners and service providers can be found in section 7, further information in section 12. Please note that there are requirements, exceptions or restrictions for these rights under applicable data protection law (e.g. to protect third parties or trade secrets). We will inform you accordingly if necessary. In particular, we may need to further process and store your personal data in order to fulfil a contract with you, to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permissible, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we can therefore reject a data subject's request in whole or in part (e.g. by blacking out certain content that concerns third parties or our trade secrets).

If you do not agree with the way we handle your rights or data protection, please let us know (Section 2). In particular, if you are in the EEA, the United Kingdom or Switzerland, you also have the right to complain to the data protection supervisory authority in your country. A list of authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_de. You can contact the supervisory authority in the United Kingdom here: https://ico.org.uk/global/contact-us/. You can contact the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/de/home/der-edoeb/kontakt/adresse.html.

12. Do we use online tracking and advertising techniques?

We use various technologies on our website with which we and third parties we engage can recognize you when you use the website and, under certain circumstances, track you over multiple visits. We will inform you about this in this section. Essentially, this means that we can distinguish between your access (via your system) and access by other users so that we can ensure the functionality of the website and carry out evaluations and personalization. We do not want to draw any conclusions about your identity, even if we can, insofar as we or third parties we engage can identify you by combining it with registration data. Even without registration data, the technologies used are designed in such a way that you are recognized as an individual visitor each time you visit the website, for example by our server (or the third party servers) assigning you or your browser a specific identification number (so-called 'cookie').

Cookies are individual codes (e.g. a serial number) that our server or a server of our service provider or advertising partner transmits to your system when you connect to our website and that your system (browser, mobile) receives and stores until the programmed expiry date. With each subsequent access, your system transmits these codes to our server or the third party server. This way, you are recognized even if your identity is unknown.

Other techniques may also be used to recognise you with a greater or lesser degree of probability (ie to distinguish you from other users), e.g. fingerprinting. Fingerprinting combines your IP address, the browser you use, the screen resolution, the language you choose and other information that your system sends to each server, resulting in a more or less unique fingerprint. This means that cookies are no longer necessary.

Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can be tracked. If we integrate offers from an advertising contract partner or provider of an analysis tool on our website, they can track you in the same way, even if you cannot be identified in individual cases.

We use such technologies on our website and allow certain third parties to do the same. You can program your browser to block, deceive or delete certain cookies or alternative technologies. You can also extend your browser with software that blocks tracking by certain third parties. You can find more information on this on the help pages of your browser (usually under the keyword 'privacy') or on the websites of the third parties that we list below. The following cookies are distinguished (technologies with similar functions such as fingerprinting are included here):

  • Necessary cookies: Some cookies are necessary for the website to work as such or for certain functions to work. For example, they ensure that you can switch between pages without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary ('session cookies'). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries you make beyond a session (i.e. a visit to the website) if you use this function (e.g. selected language, consent given, the function for automatic login, etc.). These cookies usually have an expiry date of up to 24 months.

  • Performance cookies: In order to optimize our website and corresponding offers and to better tailor them to the needs of users, we use cookies to record and analyze the use of our website, possibly even beyond the session. We do this by using third-party analysis services. We have listed these below. Performance cookies also have an expiration date, usually of up to 24 months. You can find details on the third-party websites.

  • Marketing cookies: We and our advertising partners have an interest in targeting advertising precisely, i.e. only showing it to those we want to address. We have listed our advertising partners below. For this purpose, we and our advertising partners - if you consent - also use cookies that can record the content accessed or contracts concluded. This enables us and our advertising partners to display advertising that we can assume will be of interest to you, on our website, but also on other websites that display advertising from us or our advertising partners. Depending on the situation, these cookies have an expiration date of a few days to 12 months. If you consent to the use of these cookies, you will be shown corresponding advertising. If you do not consent to these cookies, you will not see fewer advertisements, but simply different advertising.

In addition to marketing cookies, we use other techniques to control online advertising on other websites and thereby reduce wastage. For example, we can transmit the email addresses of our users, customers and other people to whom we want to display advertising to operators of advertising platforms (e.g. social media). If these people are registered there with the same email address (which the advertising platforms determine by comparing), the operators will show the advertising we have placed to these people in a targeted manner. The operators do not receive personal email addresses of people they do not already know. However, with known email addresses, they find out that these people are connected to us and what content they have accessed.

We can also integrate other third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (e.g. by clicking on a switch), the relevant providers can determine that you are on our website. If you have an account with the social media provider, they can assign this information to you and thus track your use of online offers. These social media providers process this data under their own responsibility. We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set on your behalf to control advertising):

  • Google Analytics: Google Ireland (based in Ireland) is the provider of the 'Google Analytics' service and acts as our processor. Google Ireland relies on Google LLC (based in the USA) as its processor (both 'Google'). Google uses performance cookies (see above) to track the behavior of visitors to our website (duration, frequency of pages viewed, geographical origin of access, etc.) and uses this to create reports for us on the use of our website. We have configured the service so that the IP addresses of visitors to Google in Europe are shortened before being forwarded to the USA and therefore cannot be traced back. We have deactivated the 'Data sharing' and 'Signals' settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data to draw conclusions about the identity of visitors for its own purposes, create personal profiles and link this data to these people's Google accounts. If you agree to the use of Google Analytics, you explicitly consent to such processing, which also includes the transmission of personal data (in particular website and app usage data, device information and individual IDs) to the USA and other countries. Information on Google Analytics privacy can be found here [https://support.google.com/analytics/answer/6004245] and if you have a Google account, you can find further information on processing by Google here [https://policies.google.com/technologies/partner-sites?hl=de].

13. What data do we process on our social media pages?

We may operate pages and other online presences on social networks and other platforms operated by third parties ('fan pages', 'channels', 'profiles', etc.) and collect the data about you there as described in section 3 and below. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g. about your behavior and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalize advertising) and to control their platforms (e.g. which content they show you).

We receive data about you when you communicate with us via online presences or view our content on the relevant platforms, visit our online presences or are active in them (e.g. publish content, make comments). These platforms also collect technical data, registration data, communication data, behavior and preference data from you or about you (for the terms, see section 3). These platforms regularly statistically evaluate the way in which you interact with us, how you use our online presences, our content or other parts of the platform (what you view, comment on, 'like', share, etc.) and link this data with other information about you (e.g. information about age and gender and other demographic information). In this way, they also create profiles about you and statistics on the use of our online presences. They use this data and profiles to show you our or other advertising and other content on the platform in a personalized manner and to control the behavior of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our online presence. We can partially control the evaluations that these platforms create regarding the use of our online presence.

We process this data for the purposes described in section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see section 12) and for market research. Information on the relevant legal bases can be found in section 5. We may further distribute content published by you (e.g. comments on an announcement) (e.g. in our advertising on the platform or elsewhere). We or the operators of the platforms may also delete or restrict content from or about you in accordance with the terms of use (e.g. inappropriate comments).

For further information on the processing by the platform operators, please refer to the platform's data protection notices. There you will also find out in which countries they process your data, what information, deletion and other rights you have as a data subject and how you can exercise these or obtain further information. We currently use the following platforms:

  • Goldbach Audience: LetsFamily.ch is marketed by the advertising marketer Goldbach Audience (Switzerland) AG. The advertising on the websites marketed by Goldbach Audience (Switzerland) AG is optimized for you by collecting and processing your usage behavior and is geared to predicted interests. As a user, you benefit from receiving advertising that is more in line with your areas of interest and from the fact that overall less randomly distributed advertising is delivered. A cookie is stored on your computer to record your usage behavior. The following link tells you more about how Goldbach Audience (Switzerland) AG handles the data it collects in connection with its product offerings and services and how it is stored and used. You will also be told how you can object to the data collection and deactivate it ("opt-out"): https://goldbach.com/ch/de/datenschutzerklaerung/goldbach-audience

  • Facebook: Here we operate the page www.facebook.com/letsfamily.ch. The responsible body for operating the platform for users from Europe is Facebook Ireland Ltd., Dublin, Ireland. Their privacy policy can be found at www.facebook.com/policy. Some of your data will be transferred to the USA. You can object to advertising here: www.facebook.com/settings?tab=ads. We are jointly responsible with Facebook Ireland Ltd., Dublin, Ireland, for the data collected and processed when you visit our page to create 'Page Insights'. Page Insights creates statistics about what visitors do on our page (comment on posts, forward content, etc.). This is described at www.facebook.com/legal/terms/information_about_page_insights_data. It helps us understand how our page is used and how we can improve it. We only receive anonymous, aggregated data. We have regulated our responsibilities regarding data protection in accordance with the information on www.facebook.com/legal/terms/page_controller_addendum.

14. Can this privacy policy be changed?

This privacy policy is not part of a contract with you. We may amend this privacy policy at any time. The version published on this website is the current version.

Last updated: August 20, 2023

Based on DSAT.ch